Home Health & Hospice

A Bath for Competency Testing Must Be a Bath

Homecare Insider, February 8, 2010

Homecare providers have been focused on OASIS-C.  However, we cannot forget about other challenges.  Here is one brought about by the survey process.  

Any suggestions to help us deal with a surveyor who insists that a live individual must volunteer to get a bed bath from our aides undergoing their competency evaluations?  The surveyor cited us under G218 for not testing our aides on bathing, one of the required components.  Right now, our trainees bathe individuals wearing underwear or swimming suits.  We only have one or two patients a year who need bed baths.

Agencies that perform competency testing of home health aides must pay attention to this.  A line in the Interpretive Guidelines says, “A task cannot be simulated in any manner.”  A bath implies an all-over washing of the body with a sponge or washcloth and water.  It is difficult to achieve that when a person is wearing clothes.  In 1996, the Health Care Financing Administration (HCFA), now the Centers for Medicare and Medicaid Services, issued an interpretation upholding citations similar to the one this agency received.  HCFA said, “If the aide simulates a bed bath on a clothed patient, the subject has not received a bed bath and the task has not been performed.”  

It is irrelevant how many patients need bed baths from this agency.  Aides must be competent to perform this task.  The only way to test them is to replicate the circumstances in the home and that is to bathe the skin.  This agency needs to figure out how to evaluate competency on “real” patients, either its own or under arrangement with a local health care facility.

Beacon Health offers two DVDs on bathing and personal care that can help train home health aides.  Learn more about these programs at — http://www.beaconhealth.org/cgi-bin/ccp51/cp-app.cgi?pg=prod&ref=22-320-01 and http://www.beaconhealth.org/cgi-bin/ccp51/cp-app.cgi?pg=prod&ref=22-321-01.